The Importance of OMIG Compliance Programs

Category: Client Alerts
Published: December 8, 2023

MEDICAID/OMIG Compliance Policies and Reviews Are More Critical Then Ever

Beginning July 2023, and very actively since then, NY Medicaid, through OMIG, has been conducting compliance program reviews to determine if required providers had adopted, implemented, and maintained an effective compliance program as required by 18 NYCRR Part 521, located in the OMIG Summary of Regulation document. Compliance program reviews are for a defined period and are focused on confirming the following:

  • the adopted compliance program satisfied the regulatory requirements;
  • the adopted compliance program was implemented and continuously operated for the entire review period; and
  • the adopted, implemented, and maintained compliance program was effective.

FYI: OMIG has been making unannounced visits to pharmacies throughout New York State to verify compliance with 18 NYCRR Part 521 and other Medicaid requirements.

In our experience, Medicaid compliance policies and programs are required for a vast majority of NY pharmacies. Failure to comply can result in costly fines, remediation efforts, and possible exclusion from Medicaid.

The process of drafting effective compliance policies and certification has become significantly more complicated in recent years. Even if you have compliance policies in place, they may not be relevant to the new OMIG regulations. Given the recent transition to the Medicaid fee-for-service model, the need for compliance programs and policies is exceptionally important. 

We urge you to contact our firm to review your existing compliance policies, get more information regarding new OMIG regulations, or to get assistance in drafting and implementing Medicaid compliance policies. 

At MDRXLaw, we focus on supporting pharmacy providers and have extensive experience drafting effective compliance policies and addressing OMIG compliance issues. If you need a compliance program drafted or reviewed, or have a question about the need for your pharmacy to have an OMIG compliance program, feel free to reach out to our compliance team.